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Patrick Traylor
Patrick Traylor
Partner — Environmental & Natural Resources
E: ptraylor@velaw.com T: +1.202.639.6734
VCard BIO PDF
Partner — Environmental & Natural Resources

Patrick Traylor

Patrick Traylor
Washington, D.C.
T: +1.202.639.6734
F: +1.202.879.8834

2200 Pennsylvania Avenue NW
Suite 500 West
Washington, D.C. 20037

Houston

Texas Tower
845 Texas Avenue
Suite 4700
Houston, Texas 77002

E: ptraylor@velaw.com
VCard BIO PDF
Patrick Traylor

Companies around the world have turned to Patrick for almost twenty-five years to represent them in environmental enforcement cases and to conduct their most sensitive internal environmental compliance investigations. Most recently, Patrick was the Deputy Assistant Administrator for the U.S. Environmental Protection Agency’s Office of Enforcement and Compliance Assurance (OECA), where he served as one of the highest-ranking environmental enforcement attorneys in the federal government.

During his tenure at the EPA, Patrick supervised the agency’s nationwide Clean Air Act (CAA) civil enforcement docket. He was also integrally involved in the development of every significant enforcement policy and represented OECA in reviewing all CAA regulations and guidance issued by the EPA. Patrick leverages this insight into the EPA’s CAA enforcement process to effectively and efficiently represent clients facing enforcement investigations and actions.

In addition to his litigation practice, companies in the energy sector have turned to Patrick to secure project-critical environmental approvals for the construction and expansion of tens of billions of dollars’ worth of projects at refineries, petrochemical and fertilizer plants, LNG export terminals, and coal- and gas-fired power plants.

In his environmental enforcement practice, Patrick’s clients value his thorough preparation, efficient case management, straight talk, an even temperament, and above all, a focus on his clients’ legal objectives to assist in accomplishing their business goals. His recent experience in the senior leadership of the EPA makes him a trusted advisor and effective advocate for companies that are facing the high stakes of complex environmental enforcement matters, particularly under the CAA. Patrick’s clients also value his team-based approach to integrating business, technical, and legal disciplines to develop effective and innovative permitting and project development strategies.

Prior to his service at the EPA, Patrick spent the first two decades of his legal career at a Global Top Ten law firm where clients relied on him to represent them in a variety of environmental enforcement cases, internal compliance investigations, and complex permitting matters.

With the combined experience of being one of the highest-ranking environmental enforcement attorneys in the federal government and over twenty years in private practice, Patrick has developed a unique skill set in the areas of civil environmental litigation, complex environmental permitting, and environmental enforcement investigations that makes him a trusted advisor to clients worldwide.

Environmental Enforcement Defense

  • Represents multiple independent oil and gas producers in Clean Air Act enforcement matters brought by the EPA related to the companies’ upstream production assets

  • Represents a private equity portfolio company in a Clean Air Act enforcement matter at a petrochemical facility initiated by Harris County, Texas and the Texas Commission on Environmental Quality

  • Represents a major industrial manufacturer with respect to compliance with the EPA’s nonroad engine rules

  • Represents multiple entities under investigation by the EPA for potential violations of Clean Air Act tampering and defeat device prohibitions

  • Represents a major engine manufacturer with respect to compliance with Clean Air Act certification matters

  • Represents multiple companies in making significant environmental audit disclosures to EPA and state environmental agencies

  • Represented a West Virginia wind energy facility in a U.S. Fish & Wildlife Service (FWS) criminal enforcement case under the Migratory Bird Treaty Act

  • Represented a gas-fired power plant operator in Texas in an internal investigation under the CAA

  • Represented a chemical manufacturer in Texas in an internal investigation under the CAA

  • Represented a Wyoming wind facility in a U.S. FWS criminal investigation under the Bald & Golden Eagle Protection Act

  • Represented a Maryland wind facility in a citizen suit case under the ESA

  • Represented a surface coal mine operator in New Mexico in a citizen suit case under the National Environmental Policy Act

  • Represented an underground coal mine operator in New Mexico in a citizen suit case under RCRA

  • Represented a coal-fired power plant operator in North Dakota in an EPA and North Dakota enforcement case under the CAA

  • Represented importers of tropical hardwoods in citizen suit cases under the Convention for the Import of Threatened and Endangered Species

  • Represented numerous coal-fired power system operators across the country in EPA, state, and citizen suit enforcement cases under the CAA

  • Represented automobile and engine manufacturers in EPA enforcement cases under the CAA

  • Represented coal-fired power plant operators in judicial challenges to their CAA construction permits

  • Represented a pork processing company in Virginia in an EPA enforcement case under the CWA

  • Represented a hazardous waste disposal company in a CERCLA cost reimbursement action against EPA

  • Represents a major natural gas transmission pipeline company in obtaining a Clean Air Act permit for a compressor station that is the subject of intense opposition

  • Represents a major oil refining company in the Clean Air Act permitting of an offshore crude oil export terminal

  • Represents a private equity portfolio company in Clean Air Act permitting of a liquified natural gas regasification and power production project

  • Represented an energy company in a major expansion of its refining capacity in Texas by securing a PSD permit

  • Represented a chemical manufacturing company in obtaining a PSD permit that would allow the continued use of its on-site power island

  • Represented an oil company regarding its use of anthropogenic CO2 in enhanced oil recovery operations

  • Represented a fertilizer manufacturing company in obtaining a PSD permit that would allow for a major expansion of its manufacturing operations in the Midwest

  • Represented a major international mining company in the expansion of coal mines in the American Southwest, including evaluating climate change-related impacts of coal combustion

  • Represented an ammonia manufacturing company in obtaining a PSD permit that would allow for the construction of a major new facility on the Texas Gulf Coast

  • Represented a waste-to-energy facility in obtaining a PSD permit that would allow for the construction of a new unit in an eastern state

Credentials

  • The George Washington University Law School, LL.M, Environmental Law, 1996
  • South Texas College of Law, J.D. (Member, South Texas Law Review), 1994
  • Texas A&M University, B.A., History, 1991
  • Deputy Assistant Administrator, U.S. Environmental Protection Agency, Office of Enforcement and Compliance Assurance, 2017–2019
  • Chambers USA, Environment (District of Columbia), 2012, 2013, 2022, and 2023
  • Selected to the Washington, DC Super Lawyers list, Super Lawyers® (Thomson Reuters), 2014–2015
  • Legal 500 U.S., Environment: Regulatory, 2020, 2022, and 2023; Environment: Litigation, 2022
  • Selected to the Lawdragon Green 500: Leaders in Environmental Law, 2023
  • Who’s Who Legal (Law Business Research Ltd.), Environment, 2023
  • District of Columbia
  • Texas
  • Supreme Court of the United States
  • U.S. Court of Appeals, D.C. Circuit
  • U.S. Court of Appeals, Tenth Circuit
  • U.S. District Court, District of Columbia
  • U.S. District Court, District of North Dakota
  • U.S. District Court, Southern District of Texas
  • Patrick D. Traylor, Grant Tolley, Hannah M. Flesch, Simon A. Willis & Ryan
    Vanderlip, “Energy Crimes – Federal and State Criminal Prosecutions in the Energy Sector,”
    68 Nat. Resources & Energy L. Inst. 30-1 (2022)
  • “EPA’s National Compliance Initiatives: Understanding EPA’s Enforcement Priorities in 2020-2023,” American Bar Association National Enforcement Conference, November 12, 2019 (panelist)

News & Insights

Event Recap
Making Sense of Methane for the Oil and Gas Sector: EPA’s New Methane Tax, Operating Regulations, and GHG Reporting
Environmental
March 13, 2024
Video
Insight
A Heavy Lift: EPA Bulks Up Oil and Gas Methane Requirements in New Quad Ob/c Regulations

V&E Environmental Update

Energy TransitionEnvironmental
March 8, 2024
Insight
The EPA’s Methane Waste Emission Charge: A Tax by Any Other Name

V&E Environmental Update

Environmental
February 8, 2024
Deals & Cases
Occidental to Acquire CrownRock, Strengthening its U.S. Onshore Portfolio with Premier Permian Basin Assets
December 11, 2023